Pre CFPB Federal Regulation of Payday Lending

The truth, much like almost all for the other FTC cases that are payday-lending-related ended up being immediately settled.

Ahead of the enactment regarding the Dodd-Frank Act (the Act), federal enforcement of substantive customer financing rules against non-depository payday lenders had generally speaking been limited by prosecution that is civil the Federal Trade Commission (FTC) of unfair and misleading functions and techniques (UDAP) proscribed by federal legislation. Even though it might be argued that unjust techniques had been included, the FTC failed to pursue state-law rollover or usury violations. Due to the general novelty of this tribal financing model, as well as perhaps more to the point due to the tendency of FTC defendants to be in, you will find no reported decisions concerning the FTC’s assertion of jurisdiction over TLEs. Plus »